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4shared Privacy Policy

Last Revised: March 24, 2020

This privacy policy ("Policy") explains how information you provide to us is collected, used and disclosed by
4shared ("we" or "us") with respect to your access and use of 4shared's online file storage and sharing
service located at www.4shared.com, (the "Service") and our mobile applications ("Apps" or "App"),
collectively, our Digital Properties, so you can make an informed decision about using the Service.

We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have
been made by indicating on this Policy the date it was last updated. We encourage you to review this Policy
from time to time to make sure that you understand how any information you provide to us or collected about
you will be used.

1. Personal Data Collection and Use

1.1. Data You Choose to Provide to Us

4shared collects Personal Data during your registration at our Digital Purposes, when you choose to
provide it, such as your name and email address.

The decision to provide such data is optional. However, if you choose not to register or provide this data,
you may not be able to access certain features or services available within our Digital Properties.

Your consent to the collection and use of Personal Data will be logged by us.

In addition, you can voluntarily provide us with additional data in forms as part of the registration
process. The voluntary provision of this data is a consent to the use of the data.

4shared may use the Personal Data you choose to provide to us to operate and improve our Digital Purposes,
such as to provide notices about our Website, Services and Apps, process your Service inquiries, and request
customer feedback.

4shared may also use such Personal Data to send you the information regarding new Products, Services or
features available within our Digital Properties; solely in accordance with your granted permissions.

You may unsubscribe from our newsletters and marketing emails anytime.

Log information such as the date and time of a visit or use of Digital Properties, pages visited on this
Service and areas accessed in the App, time spent viewing the Digital Properties, and return visits to the
Digital Properties, your 4shared account ID, and your 4shared account activity.

Aggregated information as you and others browse and use our Digital Properties.

Such Personal data is collected and stored in the pseudonymized manner and can not be attributed separately
to identify or reveal a natural person's individual identity.

The collected Personal Data may be used for such purposes as:

To respond to your inquiries and requests.

To operate our Digital Properties and improve your experience.

To identify or repel possible threats to Digital Properties security.

To conduct research about Digital Properties usage.

For advertising purposes in order to deliver the most relevant ads to you.

To plan and evaluate wireless networks.

To analyze aggregate consumer trends.

To conduct cybersecurity research.

1.3. Personal Data Obtained from Other Sources

4shared allows you to sign up and log in using your Facebook, Twitter or Google accounts.

a. Facebook

If you sign up using Facebook, Facebook will ask your permission to share certain information from your
Facebook account with 4shared. This information is collected by Facebook and is provided to us under the Terms
of Facebook Data Policy.

b. Twitter

If you sign up using Twitter, Twitter will ask your permission to share certain information from your Twitter
account with 4shared. This information is collected by Twitter and is provided to us under the Terms of
Twitter Privacy Policy.

c. Google

If you sign up using Google, Google will ask your permission to share certain information from your Google
account with 4shared. This information is collected by Google and is provided to us under the Terms of Google
Privacy Policy.

2. Use of Cookies and Similar Technology

We may also automatically collect certain Personal Data through the use of cookies, beacons and other similar
technology to collect aggregated statistics related to the use of our Apps and Services and improve the
performance of our Digital Properties.

a. Service provision cookies

While you are visiting the Website, our web servers for the operation of the Service temporarily collect
general technical information, in particular about the software and hardware you use, the IP address of the
requesting computer, which websites you have visited and when, and the Duration of your visit.

We use such service provision cookie technology to help you navigate our Website and enhance your experience
with our Services and features.

Such cookie technology is non-privacy intrusive, as the collected data has no personal reference to
you.

In case of a user login, however, we set a cookie, which then remains stored to enable automatic login
(permanent cookie).

b. Service performance cookies

We may use third-party analytics and research services, such as Google Analytics to better understand how
visitors interact with our Digital Properties, e.g. collect data such as where visitors came from, what
actions they took, and where visitors went when they left Digital Properties.

This data is collected and stored in the pseudonymized manner and can not be attributed separately to
identify or reveal a natural person's individual identity.

We use this information to improve your experience when visiting our Digital Properties. We may also work
with other partners to conduct research surveys in order to improve the user experience on our Digital
Properties.

3. Disclosure of Personal Data to Third Parties, Onward Transfer

a. Third-party service providers

We may share your Personal Data with third-party service providers who may assist us in responding to your
inquiries or requests, or otherwise perform some business or operational function for us.

We require that such third-party service providers confirm their Personal Data Privacy and Protection
practices are consistent with those applicable via our Digital Properties.

Any use of Personal Data by such Service Providers for the purposes other than performing business or
operational function for 4shared and its Digital Properties is strictly prohibited.

b. Third-party advertising partners

We partner with third-party ad networks to display advertising within our Digital Properties. Our ad network
partners use Web beacons and log files to collect data about your activities on our Digital Properties to
provide you targeted advertising based upon your interests.

This data is collected, stored and disclosed in the pseudonymized manner and can not be attributed separately
to identify or reveal a natural person's individual identity.

The use of cookies and beacons by our partners is not covered by our privacy statement. We do not have access
or control over these cookies.

c. Third-party targeted interest-based advertising data providers

Notwithstanding any other provision, we partner with third parties that collect information across various channels,
including offline and online, for purposes of delivering more relevant advertising to you or your business.

Our partners may link the hashed or obfuscated personal information we share with them to the cookie stored on
your browser or device, and they may collect information such as your IP address, browser or operating system
type and version, and demographic or inferred-interest information.

Our partners use this information to recognize you across different channels and platforms, including but not
limited to, computers, mobile devices, and Smart TVs, over time for advertising, analytics, attribution, and reporting
purposes. Your data may be transferred outside of the country from which it was originally collected.

For more details on the collection, use and disclosure of Personal Data, and instructions on how to opt out of
interest-based advertising, please refer to information provided below or visit websites of advertising
networks and data providers:

internal business processes and management, age verification or authentication purposes, fraud detection and prevention, and compliance with governmental, legislative and regulatory bodies

sales and marketing

For further information about MobKnow data practices, including technical and organizational measures to ensure that personal data are not attributed to an identifiable natural person, please see the MobKnow Privacy Policy.

To opt out of data sharing with MobKnow, please utilize the opt-out measures provided in the privacy statement, contact DPO@mobknow.com, or contact us at legal@4shared.com.

ResultsData will use anonymized user data for online targeted advertising throughout the user's browsing experience.

provision, operation, management, maintenance, and enhancements of the AMP

For further information about adsquare data practices, including technical and organizational measures to ensure that personal data are not attributed to an identifiable natural person, please see the adsquare Privacy Policy.

OpenSignal collects data on mobile network coverage and performance. We use the crowdsourced data collected from users' devices to publish reports and metrics on mobile network experience. You can see the reports we publish here: http://opensignal.com/reports

OpenSignal is the independent global standard for measuring real-world mobile network experience. We believe measuring how the network performs directly through users' eyes is key to building better wireless networks.

Tutela Technologies Ltd. collects data relating to your use of our apps, other apps and your device,
that may include (a combination of) Personal Data elements, such as:

Location

Wireless network performance, usage, and identifiers, and

other permission-based user information.

Data is shared with wireless service providers and other third parties who use it to analyze aggregate
consumer mobile trends, improve your wireless networks, and conduct cyber-security research.

Outside of GDPR participating countries, mobile advertiser ID may be shared for network marketing and
advertising purposes in accordance with the Digital Advertising Alliance principles. No data is stored by
Tutela for longer than 12 months.

For further information about Tutela's data practices, including technical and organisational measures to
ensure that personal data are not attributed to an identifiable natural person, please see the Privacy
Charter.

To opt out of data sharing with Tutela, please utilize the opt-out measures provided in the privacy
statement, contact data.protection.officer@tutela.com, or contact us at legal@4shared.com.

TrueData Solutions, Inc. may collect the following data elements, including:

mobile advertising identifiers such as IDFA and Google AdID,

location data,

device and hardware data,

application install data,

other types of user-level data.

TrueData Solutions, Inc. may utilize the collected information with agencies, brands, and other companies that use mobile data for various advertising services such as mobile ad targeting, ad and audience analytics.

X-Mode Social, Inc. may collect the following data elements, including:

Precise location information (device GPS coordinates)

Relative location information (from WiFi signals)

Device-based advertising identifiers

Type of device, operating system version and type

Device settings

Timezone, carrier

IP address

X-Mode Social, Inc. may utilize the collected information to customize ads in this or other; to measure
effectiveness of those ads, or for market, civic or other research regarding aggregated traffic patterns.

For further information about X-Mode Social, Inc. data practices, please refer to X-Mode Social
Privacy Policy.

For more information and available opt-out mechanisms, regarding interest-based advertising, please refer to "Your Choice and Control" section of this Privacy Policy, below.

d. Legally required disclosure. Additional notes

We may also disclose your Personal Data if required by law, including without limitation, by search warrant,
subpoena or court order; to protect our and third-party rights; and for purposes disclosed at the time of
collection.

4. Your Choice and Control

We do our best to provide you choice and control, with regard to Personal Data and other information you provide to us.

It is not necessary for you to provide us with any Personal Data in order to visit our Website and use our Services, although certain information is being collected automatically during your visit (as described above).

If you register a 4shared account, you can control your Personal Data in a number of ways within your your 4shared account settings on our Website.

4.2. Right to Withdraw Consent

You may withdraw your consent to the collection and use of Personal Data by 4shared - generally or with regard to the additionally voluntarily communicated data in accordance with effect for the future.

However, in the event of your cancellation, certain features that require registration may no longer be provided. This does not apply to the revocation to collect further voluntary data, provided to us.

To withdraw your consent to the collection and use of your Personal Data by 4shared, please send us a corresponding inquiry via email legal@4shared.com.

You may also unsubscribe from our newsletters and marketing emails by clicking on the Unsubscribe links,
provided in such emails.

4.4. Opting Out of Personal Data Disclosure to Social Networks

The Social Networks tab within your account Settings on our Website enables you to control the information you share with social networks via connected accounts.

To opt out of your data collection by Facebook, Twitter or Google, use the "Disconnect" option for the corresponding account in the Social Networks tab within your 4shared account Settings on our Website.

4.5. Opting Out of Personal Data Disclosure to Other Users

4shared doesn't claim ownership of Your Content.

4shared doesn't use what you say in email, chat, your files, documents, photos, videos and other Content to target advertising to you.

4shared enables you to store or share Your Content, access or download content, shared by other users. When you share Your Content with others, you acknowledge that they may be able to save, record, reproduce, share, transmit, broadcast, display or otherwise use Your Content without providing any compensation to you.

If any of your Content contains (a combination of) Personal Data elements or any other information that you would not like to share, you can limit other users' access to this Content within your 4shared account - by making a file "Private" or setting up "Private access" to a folder, correspondingly.

For more details on how to secure and protect your Content, please visit 4shared Security page.

4.6. Opting Out of Interest-Based Advertising

To opt out of interest-based advertising, please refer to the following opt-out options and mechanisms:

Please note that even if you opt out of interest-based advertising, 4shared may continue to collect data for
other purposes, 4shared will still display generic ads (i.e. not targeted to you), while using our Digital
Properties.

4.7. Opt-Out Options in 4shared Applications

For more information on the collection, use and disclosure of Personal Data via 4shared Applications and your opt-out choices, please refer to 4shared App Privacy Statement.

5. Data Security

We take reasonable measures to help maintain data we collect through our Digital Properties in a secure
manner.

6. Data Retention

4shared will not retain, use or process shared Personal Data, such as your email address, for longer than
necessary to fulfill our business purpose.

We store non-personally intrusive data and the Personal Data obtained from the Use of our Digital Properties,
in a pseudonymized manner, up to one year in order to ensure that our Digital Properties function
properly.

7. Data Integrity, Purpose of Limitation

We process information in a way that is compatible with and relevant to the purpose for which it was
collected as described above. To the extent necessary for those purposes, we take reasonable steps to ensure
that any information in our care is accurate, complete, current and reliable for its intended use.

8. Reviewing and Updating Personal Data

4shared takes reasonable steps to ensure that information is accurate, complete, current, and reliable for
its intended use.

For the Data you choose you provide us with, you may review, correct, update, or change your Personal Data,
request that we deactivate your account, or remove your Personal Data from our direct marketing efforts, at
any time by emailing us at legal@4shared.com.

9. Information Relating to Children

Our Digital Properties are designed for people 18 years of age and older.

4shared does not knowingly collect Personal Data from anyone under the age of 18. If 4shared is made aware that
it has received Personal Data from someone under 18, it will use reasonable efforts to remove that information
from its records.

4shared is committed to compliance and adherence to Personal Data privacy and protection laws, rules and
regulations, including:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection
of natural persons with regard to the processing of personal data and the free movement of such data, and
repealing Directive 95/46/EC (General Data Protection Regulation);

regulatory guidelines;

any of the applicable self-regulatory guidelines.

If there is any conflict between the Terms of Use or other policies described in this Privacy Policy, the
Policies covered in this Section shall govern.

10.1. Data Retention

Retention of personal information of EEA and Swiss individuals will be handled in accordance with 4shared
Data Retention policy (as described above).

10.2. Accessing and Deleting Personal Data

EEA and Swiss individuals have the right to access the personal information that 4shared maintains about you,
as that term is defined in EU data protection and privacy regulations, including GDPR principles, and you may
be able to correct or amend that information if it is inaccurate or has been processed in violation of the
GDPR principles, to the extent allowed by applicable law.

EEA and Swiss individuals have the right to:

request access to and rectification or erasure of personal information;

restrict the processing of personal information, object to processing, and/or exercise the right of data
portability; and

withdraw consent without affecting the lawfulness of processing and lodge a complaint with a supervisory
authority.

To exercise this right, please send us a corresponding email inquiry at pi@4shared.com.

For any requests or information regarding the rights set out above, please contact us by emailing us at
pi@4shared.com.

4shared is committed to resolving of complaints about our collection or use of your personal information. EEA
or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact 4shared
at pi@4shared.com.

10.3. Disclosure of Personal Data to Third Parties, Onward Transfer

4shared may transfer Personal Data elements of EU and Swiss individuals received to third parties, as described
above in this Privacy Policy. The Personal Data disclosed will be used for the purposes set forth in this
Privacy Policy.

You may request disclosure, notification of the intended purpose, correction, addition, deletion, and
cessation of use or cessation of disclosure to third parties of your Personal Data by emailing us at
pi@4shared.com.

Where 4shared has disclosed Personal Data of its User to any third parties, and the User has subsequently
exercised any of the rights of rectification, erasure or blocking, 4shared will promptly notify those third
parties of the User's exercising of those rights. In no case 4shared shall be liable for the failure of any
third party to comply with such User's request.

4shared is exempt from this obligation if it is impossible or would require disproportionate effort.

Where 4shared has made Personal Data of its User public, and the User exercises any of the rights as
described above, 4shared will take reasonable steps to inform third parties that the User has exercised those
rights.

10.5. Collection and Use of Sensitive or Special Categories of Personal Data

4shared does not knowingly collect, store or in any other way process Sensitive or Special Categories of User
Data, such as: Personal Data, revealing racial or ethnic origin, political opinions, religious or
philosophical beliefs, trade-union membership; Data concerning health or sex life and sexual orientation;
genetic data or biometric data; Personal Data of Children below the age of 18 years.

If 4shared is made aware that it has received (a combination of) such Sensitive Personal Data elements, we
will use reasonable efforts to remove this Data from our records.

11. Legal Basis for the Processing of Personal Data of California Residents

4shared is committed to compliance to Personal Data privacy and protection laws and regulations, including California Consumer Privacy Act (CCPA).

If there is any conflict between the 4shared Terms of Service or Privacy Policy, the Policies covered in this Section shall govern.

11.1. Personal Data Rights of California Residents

Pursuant to California Consumer Privacy Act (CCPA), registered 4shared Users who are California residents have the right to:

11.2. Opting Out of the Sale of Personal Data

Pursuant to Civil Code Section 1798.120, registered 4shared Users who are residents of California have the right to opt out of the Sale or of their Personal Data collected via our Website and Mobile Applications anytime.

If you are a California resident, have a registered account at 4shared, and wish to exercise this right, please follow the opt-out instructions below.

For more information on how to opt out of the sale of Personal Data collected via out Apps, please please refer to 4shared App Privacy Statement.

Non-discrimination: please note that your choice to opt out of the Sale of Personal Data does not affect the amount and quality of services, provided by 4shared.

11.3. Processing of Children's Personal Data

Our Services are intended for use by individuals 18 years of age and older.

If we are made aware that 4shared has obtained Personal Data of Children below the age of 18 years, we will use reasonable efforts to remove this Data from our records.

12. Other Important Privacy Information

12.1. Links to Third-Party Websites

Our Digital Properties may contain links to other websites operated by third parties. We do not own or
control such websites and this Privacy Policy applies solely to information collected through our Digital
Properties. Their data practices are regulated by the privacy statements of these websites.

12.2. Contact Us

If you have questions about this Privacy Policy, please contact us at legal@4shared.com.

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